National MDS 3.0 training call recap

Wow, we are closing in on one year of using the MDS 3.0 and are finally getting the “hang of it” with all the changes that occurred with its implementation. After all these months, MDS coordinators have grown accustomed to getting the interdisciplinary team to complete the interviews within the allowable timeframes, addressing all new items on the assessment and coordinating the different data sets. Actually, many MDS coordinators will now admit that the MDS 3.0 assessment, although 38 pages long, is “really not that bad.”

Then, just like the earthquake that interrupted Tuesday’s national provider training call on MDS 3.0 and RUG-IV updates for FY2012, CMS shakes us with multiple process and MDS changes that will become effective on October 1, 2011.

The MDS Assessment schedule for PPS assessments is changing. The 5-day assessment is the only one that maintains an Assessment Reference Date (ARD) selection choice of day one through day five with three allowable grace days. After that assessment, all of the other of ARD selection choices for the 14-, 30-, 60- and 90-day assessments will be different. CMS is implementing this change to avoid capturing the same assessment data on more than one assessment.

(Really, if you think about it, information for the 5- and 14-day assessments can be and often is the same. Facilities are getting reimbursed for days 15 through 30 of the resident stay at RUG-IV levels for the 14-day assessment based on events that occurred as early as day five of a resident’s stay.)

The confusion over whether a center is a 5-, 6- or 7-day provider of therapy services will be resolved once and for all. As a senior living services consultant, I can’t count how many times I have had the discussion with therapy managers on the determination of how many days they provide therapy a week. Beginning October 1, an End of Therapy OMRA must be completed whenever therapy is not provided for three consecutive days regardless of the reason.

In addition to the EOT OMRA update is a new assessment called the “End of Therapy with Resumption” or EOT-R; this assessment may be completed if the resident, who missed three consecutive days of therapy, resumes therapy at the same level as prior to the missed days. The EOT-R will indicate the resident is at the same RUG level for billing after therapy resumed and will determine a non-therapy RUG category to be billed for the missed therapy days.

Further rumblings on the training call were heard when CMS described another new assessment type: the Change of Therapy OMRA. (And I’m pretty sure it wasn’t the East Coast earthquake rumbling I heard). Effective with all assessments with an ARD on or after October 1, a COT OMRA will be required whenever a resident does not maintain the intensity of therapy of the RUG-IV classification level determined on the most recent PPS assessment. This new assessment will require additional time constraints on the MDS coordinator. Communication between the therapy department and the MDS coordinator will be even more crucial than it is now.

A review of therapy minutes during the COT observation period will need to be done. The COT observation period begins the first day after the ARD of the most recent assessment and continues for seven days. On the seventh day, if the intensity of therapy is not at the same level it was as of the most recent PPS ARD, the COT OMRA must be completed. A new RUG-IV classification will be established from this assessment and will be retroactive back to the first date of the COT observation period. The therapy intensity review is an ongoing review to be done every seven days—in other words, a new COT observation period will begin after the last COT observation period ends.

Just when we thought we were all finally getting our act together with MDS 3.0, the industry gets hit with these changes and the confusion begins again. Change is the name of the game. For further clarification and training, refer to the CMS Open Door Forums. A Special Open Door Forum repeating this call’s training will take place on September 1 at 2 p.m. ET.

Tracy Burger Montag, RN, BSN, RAC-CT, is a senior consultant of the Senior Living Services Consulting Group for Reinsel Kuntz Lesher LLP of Lancaster, Pennsylvania. Montag has more than 20 years’ experience working with the Minimum Data Set and is an MDS 3.0 Gold Standard Nurse who co-lead the MDS 3.0 pilot project for Pennsylvania. She most recently participated with CMS in two training videos: MDS3 Facility Leadership and MDS3 Interdisciplinary Team.